Environmental Protection Agency (EPA) Methane White Paper

Oil and Natural Gas Sector Pneumatic Devices

INGAA Comments

1. Introduction

The Interstate Natural Gas Associ ation of America (INGAA), a trade association of the interstate natural gas pipeline industry, submits these co mments on the EPA’s technical white paper, “Oil and Natural Gas Sector Pneumatic Devices” (P neumatics Paper). On April 15, 2014, the EPA released five technical white papers discussing po tentially significant sources of emissions in the oil and natural gas sector. Specifically, the white papers focus on potential emissions and mitigation techniques for methane and volat ile organic compounds (VOCs). INGAA is submitting separate comments on the three papers (Compressors, Leaks and Pneumatics) that address sources applicable to the interstate na tural gas transmission and storage (T&S) sector. These comments address the Pneumatics Paper.

In the Pneumatics Paper, EPA summarized its current understanding of VOC and methane emissions from this source category, and its current understanding of available mitigation techniques and the cost, effectiveness and applic ation of these techniques in the oil and natural gas sector. EPA has requested comment on ni ne questions related to the contents and conclusions of the Pneumatics Paper.

INGAA and its member companies have a long histor y of working collaboratively with a variety of stakeholders on numerous greenhouse gas (GHG) related issues, including methane quantification and mitigation. As such, INGAA welcomes the opportunity to contribute its knowledge of emissions and available cont rol technologies. INGA A commends EPA for involving stakeholders and inviting comment on the methane white papers.

Executive Summary

INGAA has three general points in response to EPA’ s white papers. First, there are significant

differences in the methane emission estimates produced by EPA’s Inventory of U.S. Greenhouse Gas Emissions and Sinks (the National Invent ory) and the Subpart W portion of its Greenhouse Gas Reporting Program (GHGRP). 1 There also are significant gaps in the information available. EPA needs to develop a systematic program to re concile these differences and fill the gaps in order to support further di scussion on methane reductions . Second, INGAA recommends additional discussion and analysis of the implicat ions, including costs, of potential mitigation methods. Finally, EPA should recognize that new information will be available soon to supplement this discussion.

1 See http://www.epa.gov/ghgreporting/ and http://www.epa.gov/ghgreporting/ reporters/subpart/w.html ( Starting with the 2011 calendar year for Subpar t W, the GHGRP requires pipeline companies to submit annual reports of GHG emissions for subject facilities. Pipelines must submit 2014 emission information for the fourth annual report by March 31, 2015).INGAA Comments on EPA Pneumatic Devices White Paper June 16, 2014

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Page 2 of 12 In response to the Pneumatics Paper specifi cally, INGAA offers the following comments:

1. EPA should reevaluate whether pneumatics are relevant to the inte rstate natural gas transmission and storage (T&S) sector. I NGAA submits that pneumatics is an upstream issue but not a significant emi ssion source for the T&S sector.

2. Gas-driven pneumatics are needed for some pr ocess applications to address rapid process control, possibly due to safety concerns, such as large valves that are used to isolate portions of the facility or pieces of equipment.

INGAA welcomes the opportunity to contribute to this discussion.

Overview of INGAA Responses

INGAA has attempted to answer each question to th e best of its ability. Due to time and other limitations, however, INGAA has not answered all questions fully. For some questions, INGAA could not respond completely because this will require a significant long-term effort (e.g., a research program) that includes all stakeholde rs. For example, quest ions regarding technology prevalence, cost implications and technical feasibility impact s would entail an integrated research effort to provide a quality, validated and vetted answ er. In most cases, however, INGAA has provided a thorough response with the in formation available while noting the gaps in existing data. Whenever possible, INGAA offe rs specific examples of field conditions and industry experience. Appendix A provides a quic k reference to EPA’s questions on pneumatic devices and INGAA’s response.

2. Establish an Open Process That Involves A ll Stakeholders to Fu rther Examine Methane

Reduction Issues

Other than the Natural Gas STAR program, EPA has focused its oil and gas industry GHG efforts primarily on quantifying or estimating me thane emissions. EPA must consider a number of issues, including economic, operational and e nvironmental issues as it moves toward a broader methane strategy.

INGAA envisions a process that is transparent and inclus ive of industry and other stakeholders to examine issues and potential strategies. This ha s proven effective at othe r federal agencies and for other EPA regulations. For example, EPA c ould host technical confer ences similar to those convened by the Federal Energy Re gulatory Commission (FERC) to examine critical issues prior to initiating a rulemaking. 2

2 FERC typically holds public technical conferences to gath er information on important policy issues and to hear potentially competing positions in advance of issuing significant rulemakings. For example, in 2012-2013, FERC

held a series of technical conferences to explore issues surrounding the incr eased use of natural gas for electric power generation and issues that may impede coordination between the gas and electric industries. After considering discussions raised by inte rested stakeholders at the 2012-2013 technical conferences, and subsequent public comments, the FERC initiated two rulemakings that pro pose to address concerns raised by participants at the

technical conferences. Technical confer ences provide the benefit of educating the regulator and other stakeholders on a particular issue and facilitating a structured dialogue where stakeholders can debate the effectiveness or need for prospective action prior to the issuance in a propos ed rulemaking. Often techni cal conferences can reveal stakeholder support for certain initiatives, identify potential flaws in certain proposals, and identify alternative ways to address the regulator’s or stakeholders’ concerns.INGAA Comments on EPA Pneumatic Devices White Paper June 16, 2014

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Page 3 of 12 This process would provide an efficient a nd effective means to advance the current understanding of methane emissions and how to de sign effective programs. As an example, the EPA GHGRP is intended to develop improved G HG inventories and to inform policy decisions. 3
Subpart W of the GHGRP addresses T&S segmen t emissions from vents and equipment leaks and companies have submitted three years of data to date. Data is publicly available for the 2011 and 2012 reporting years, 4 and indicate significant dispari ties between Subpart W reporting and the U.S. National Inventory 5 for T&S sources. These differences are due in part to differences in scope but also other reasons. It is very important that these differences are understood and that a single, accurate inventory is in place before EPA or industry can develop and implement effective and efficient mitigation strategies. Th ese proposed technical conferences or workshops can provide EPA and industry the pl atform to discuss these important issues so that EPA’s future methane reduction policies reflect all relevant analysis.

3. Sources of Information on Emissions and Reduction Opportunities 6

EPA has requested comment on whether the Pneu matics Paper appropriately characterizes the

different studies and data sources . INGAA agrees that it is im portant to understand the sources of methane emissions, how those emissions are measured and reported, what reduction opportunities exist (and what is the cost associated with th ese opportunities). While the Pneumatics Paper provides a summary of several sources of information, the paper does not

reflect the full breadth of valuable information av ailable to EPA on the topic. Further, while the studies have been summarized, they are neither co mpared nor contrasted with each other or with

other sources of similar information. It would ha ve been valuable for EPA to provide a tabular summary that presents the primary results from each study in common engineering units in order to identify data gaps and inconsistencies. While it may not have been the intent of the Pneumatics Paper to compare or contrast informati on, such an exercise is necessary to determine if a particular study appropriately characterizes the data available. Further, a comparison of the studies would help identify conflicts and data gaps in the information.

Due to the limited comment period, I NGAA did not have time to deve lop a definitive analysis of

the various studies listed or a list of key studies that were not included. However, more detailed discussion below provides examples of data gaps or differences in the primary tools that are being used to inform the process (e.g., differe nces between Subpart W reporting and the National Inventory).

In general, INGAA views the Pneumatics Paper as a summary of some information, but not the full range of studies and data sour ces currently available. EPA’s characterization that the studies presented in the paper are pivotal suggests that EPA considers them key to understanding these issues. INGAA would caution EPA against placi ng excessive weight on this limited information

3 See 40 C.F.R. Part 98 (2014).

4 EPA publishes GHGRP reporting results through its data publication tool, Facility Level Information on

GreenHouse gases Tool (FLIGHT); see http://ghgdata.epa.gov/ghgp/main.do

5 Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2012 , EPA 430-R-14-003 (April 2014). This report presents the U.S. national GHG inventory from 1990-2012 for anthropogenic sources (i.e., associated with human activity) and is referred to as the “National Inventory” in these comments. The report is updated annually.

6 This section includes responses relevant to Pneumatics Paper question 1 (emissions studies).INGAA Comments on EPA Pneumatic Devices White Paper June 16, 2014

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Page 4 of 12 since other studies, not referenced in the Pneuma tics Paper, may be based on the same or similar

data sets but reach different conclusions.

INGAA also urges EPA to elaborate on how it ar rived at its cost analysis for mitigation measures. Cost estimates are sensitive to assump tions and inherent data inconsistencies. Costs vary over time and with locat ion and chosen technology. As presented by EPA, the 2014 study by ICF, Economic Analysis of Methane Emission Re duction Opportunities in the U.S. Onshore

Oil and Natural Gas Industries

, (ICF paper) 7 appears to be the primary source of information on evaluating cost-effective emissions reduction opport unities. However, the ICF paper has several limitations such as only including emissions mitiga tion options for a subset of emission sources, only addressing one mitigation technology or wo rk practice for these select sources (i.e., alternatives are not addressed) , and generally not a ddressing uncertainties or presenting ranges associated with emission mitigation costs and performance. Further, several other sources of

similar information have not been referenced. In fact, cost-effectiveness has been examined by a number of organizations such as the Inte rnational Petroleum Industry Environmental Conservation Association (IPIECA) 8 and the Intergovernmental Panel on Climate Change (IPCC). 9 Cost effectiveness has also been a topic during the United Nations Framework Convention on Climate Change (UNFCCC) events. Given the significance of understanding the

costs associated with various methane reduction technologies in crafting a comprehensive costeffective reduction strategy, the Pneumatics Paper should expand the discussion to describe more fully the body of available info rmation, including key parameters and assumptions that impact cost analyses. As an example, the differences between Subpart W data and the National Inventory for T&S sources affects the calculation for potential achievable reductions and thus have economic analysis implications.

New sources of information soon will become av ailable that will sign ificantly add to the understanding of methane emissions and reduction opportunities in th e T&S sector. Specifically, the Pipeline Research Council International (PRCI) 10 is completing a report summarizing GHG emission reduction technologies and work practices applicab le to natural gas pipeline compressor stations. The PRCI work will id entify existing and commercially available GHG emission reduction technologies and work practices for pipeline compressor stations, as well as identify technologies in development. The repo rt will evaluate technica l and economic viability of existing and developmental GHG emission reduc tion technologies and work practices. While this report has yet to be released, PRCI has permitted INGAA to acknowledge the draft document for the purposes of our comments. More detail on pneumatic emissions reduction technologies and costs is pr ovided in comments below.

7 Economic Analysis of Methane Emission Reduction Opportunities in the U.S. Onshore Oil and Natural Gas

Industries , ICF International, 2014.

8 Oil and Natural Gas Industry Guidelines for Greenhouse Gas Reduction Projects, March 2007.

9 Climate Change 2007, the Fourth A ssessment Report (AR4) of the United Nations Intergovernmental Panel on Climate Change (IPCC).

10 The Pipeline Research Council International (PRCI) is th e global collaborative research development organization of, by, and for the energy pipeline industry.INGAA Comments on EPA Pneumatic Devices White Paper June 16, 2014

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Page 5 of 12 4. Available Emission Studies and Pneumatic Emissions Significance for T&S Facilities 11

EPA has asked for comment on the emissions st udies included in the Pneumatics Paper, the range of emissions, and information on planne d or ongoing studies. While there are several

sources of information on methane emissions fr om the natural gas system, the two primary

sources of GHG emission data are the Nationa l Inventory and the EPA GHGRP. The EPA compiles both a top-down estimate of GHG emissions (i.e., National Inventor y activity data uses data such as facility count and miles of pipe to estimate emissions) and detailed bottom-up reporting (GHGRP). The National I nventory is commensurate with a Tier 1 or Tier 2 estimate (i.e., using activity data at the facility or large unit level), wh ile Subpart W of the GHGRP uses Tier 3 (more granular source or component level activity data) or Tier 4 (detailed source level data or direct measurement) estimates. These two reports use different methods for estimating

methane releases and do not include all of the same sources of releases. Accordingly, there currently is no single compilation that comprehens ively and accurately addresses all sources of methane released by the T&S sector.

While the National Inventory and the GHGRP pr oduce consistent estimated emissions from some sources (e.g., the natural gas production segmen t), there are significant differences for the other segments of the natural gas system. There likely are multiple reasons for the disparity, including differences in the methodologies used in the two programs, an d the specific sources being measured and included for reporting. Fo r example, EPA updated key National Inventory estimates for the production segment based on more recent data, including Subpart W data. In addition, the facility definition for production captures nearly all production operations. In contrast, EPA has not yet updated its key estimate s for the T&S segment, and it does not appear that EPA has compiled or analyzed results base d on thousands of measurements for T&S sources completed in response the GHGRP reporting require ments. INGAA suggests that the approach used for production can also be used to improve the estimates for the T&S sector and to serve as a more accurate basis for determining costs and mitigation opportunities. Work to reconcile these estimates remains an area of needed analysis before drawing any definitive conclusions

about the total level of methane emissions from natural gas pipelines or definitively addressing related questions about mitigation and costs.

The need for more current data and analysis on methane emission levels is highlighted by the

fact that most T&S emission factors used fo r estimating methane emissions are based on a limited set of data that is approximately two deca des old. The emission factors that are used to

calculate methane emissions for both the Natio nal Inventory Report and for some Subpart W sources, have typically been in place since the 1990s and need to be updated. For T&S, the National Inventory (and other pub lished papers and studies) prim arily rely on emission factors

derived from an EPA – Gas Re search Institute (GRI) study 12 that was completed in the early 1990s and published in 1996. These factors may not accurately reflect na tural gas transmission methane emissions because operatin g practices, as well as the effi ciency of operating equipment,

11 This section includes responses relevant to Pneumatics Paper questions 1 and 2 (emissions studies and range), and 3 (mitigation).

12 Methane Emissions from the Natural Gas Industry, EPA/GRI report (June 1996) at: http://www.epa.gov/gasstar/tools/related.html ; This 15-volume compendium of reports is from an EPA/GRI study published in 1996 that remains a seminal reference on methane releases from natural gas systems. These reports and related data are referred to as the “EPA-GRI Study” in this paper.INGAA Comments on EPA Pneumatic Devices White Paper June 16, 2014

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Page 6 of 12 have improved over the past 20 years. INGAA urge s EPA to initiate a program to use the T&S data from 2011, 2012 and 2013 GHGRP reporting to support development of improved emission

factors.

The GHGRP also has some limitations, includ ing reliance on dated emission factors and

exclusion of smaller facilities a nd smaller sources at s ubject facilities. Subpart W also does not require reporting of known sources, such as rod packing emissions in “not operatingpressurized” (i.e., standby) mode, and centrif ugal compressor emissions from dry seals. However, analysis of the reported data shoul d significantly improve the understanding of methane emissions from the T&S sector, especi ally where measurement is required. Future improvements in estimates of aggregated methan e emissions, along with use of Subpart W direct measurements to update emission factors, can lead to more accurate estimates overall. We ask that EPA work with the industry to devel op emission factors for the sources with new

measurement data available.

Contribution of Pneumatic Devi ce Emissions for T&S Facilities 13

Review of the Subpart W and Nati onal Inventory data indicates significant differences. For the transmission segment in 2011, the National Inventory estimate is over 25 times higher than Subpart W . This is due in part to the fact that Subpart W considers only a subset of all transmission facilities, those facilities w ith annual emissions greater than 25,000 metric tons CO 2 equivalent (CO 2 e), but this would likely account for only pa rt of the difference. A more accurate

estimate for the differences based on a “nati onal estimate” using Subpart W data could be obtained by using the activity data from the Nati onal Inventory (station count) and an emission factor based on Subpart W data. The emi ssion factor would be based on dividing the transmission segment Subpart W pneumatic emi ssions by the number of reporting facilities. Even using this approach to scale up Subpart W estimates, the National Inventory estimate is over four times higher that an estimate based on Subpart W data. Considering the five primary T&S sources that report under Subpart W (i.e., reciproca ting compressors, centrifugal compressors, pneumatic controllers, equipment leaks and blowdowns), pneumatics contribute 15 percent of the National Inventory for transmiss ion but only 5 percent of the Subpart W inventory

. It is expected that the relative contribution percentage would rema in fairly consistent across all T&S facilities, including those that did not tri gger reporting under Subpart W. In addition, some

INGAA members indicated that th e portion of pneumatic emissions was even lower. As discussed below, Subpart W may include an over-estimate of pneumatic emissions for some companies because of a tendency to conservative ly count pneumatic devices as a high bleed device if the categorization (i.e., actual bleed rate above or be low the “high bleed” threshold)

was not clear.

In addition, it is possible that the 2011 Subpart W emissions have been over-reported because the count of high bleed devices may have been over-reported. The demarcation between high and low bleed devices (bleed rate of 6 SCFH) is not founded in pneumatic-device technology but is

rather an artifact of a limited analysis associated with the de vice population of a single company. There is anecdotal information that indicates opera tors were conservative in this initial estimate

and “over-counted” the number of high bleed devices. The classifi cation of high or low bleed is

13 This section includes responses relevant to Pneumatics Paper questions 1 and 2 (emissions studies and range), 5 (prevalence), and 9 (new studies).INGAA Comments on EPA Pneumatic Devices White Paper June 16, 2014

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Page 7 of 12 based on an engineering estimate using availabl e information, and in many cases, the device bleed rate was unknown. Thus, some operators, ta king a conservative approach, counted devices as high bleed if the classification was not clear. The Subpart W estimate is based on a count of pneumatic devices by device type (high bleed, lo w bleed or intermittent bleed) and an emission factor for each of the three device types. The emission factors are based on data from the 1990 EPA-GRI study.

Since the emission factors for hi gh bleed and low bleed devices di ffer by a factor of thirteen, undercounting low bleed devices an d over-counting high bleed device s would significantly affect the pneumatic device inventory. An initial revi ew of Subpart W 2011 data counts by device type indicates approximately three times as many high bleed devices as low bleed devices. That is

not consistent with the common understanding and practices of cu rrent operations, in which low

bleed and intermittent bleed devices are much more common. This further expands the difference between the Subpart W inventory and National Inventory, discussed above, and this indicates that pneumatic device emissions for compressor stations are a smaller relative contributor than indicated by th e National Inventory. This disp arity should be reconciled to ensure that potential reductions and mitiga tion costs are accurately determined prior to developing new regulatory or volun tary programs for these sources . It is possible that T&S pneumatic device emissions in practice are signi ficantly lower than estimated in the National Inventory and also potentially lower than those reported under Subpart W due to an overestimate of high bleed devices). Thus, these sources may not require further reductions. Industry continues to review available information from Subpart W reporting for 2011, 2012 and 2013, and additional insights may be gained. In addition, T&S sector results from a collaborative project that includes several natural gas transmission companies and the Environmental Defense Fund (EDF) should be pub lished later this year. That measurement program could include additional insight on the relative contribution of pneumatic devices to the T&S inventory.

INGAA has not conducted a survey of operators or tried to identif y the reasons for the inventory differences, but there are severa l possible contributing factors ba sed on our understanding of the

data and discussions with operators, including:

• The National Inventory T&S emission estimates ar e based on 20-year-old emissions data;

• In recent years, T&S operator s have switched to lower bleed devices when feasible (e.g., through the Natural Gas STAR program);

• In recent years, pneumatic devices powered by instrument air systems have replaced natural gas-driven devices at some facilities where this does not present a pipeline safety risk; and

• Operators may not have a consis tent understanding or interpreta tion of the thre e categories of pneumatic devices identified as being used with in the T&S industry. It would be beneficial to have more specific and detailed guidance established for the pneumatic devices used within the T&S industry to help eliminate the potential for different interpretations.

Several questions from the Pneumatic Paper appear to focus on upstream operations rather than T&S operations. For example, the white paper refe rences 2013 studies that report a wide range

of emissions. INGAA understands that additiona l work may be underway for upstream systems, but cannot offer insight into those issues. For the T&S sector, pneumatic pumps common in upstream operations are much less prevalent and, accordingly, emissions are expected to beINGAA Comments on EPA Pneumatic Devices White Paper June 16, 2014

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Page 8 of 12 much lower from pneumatic devices in the T&S sect or. Further, instrument air systems that may be feasible for some compressor stations are not feasible in remote areas that do not have access to electric power.

Finally, the white paper asks about factors that result in different emission rates. As noted above,

the 6 SCFH threshold used to differentiate high bleed and low bleed pneumatics is based on a limited analysis done in the past, and is not ba sed on common technical sp ecifications or design criteria. Many devices can emit at a rate above or below this threshold depending on operational requirements. Both design and operational fact ors can contribute to the bleed rate, including operational influences such as service or a pplication, supply pressure, proportional setting, output pressure range, set point pr essure, frequency of use, etc.

5. Mitigation Techniques and Costs 14

Pneumatic pumps (e.g., glycol de hydrator Kimray pumps) common in upstream operations are not prevalent at T&S facilities. Thus, our comments are focused on pneumatic controllers and not pneumatic pumps. The two primary mitigation a pproaches that are relevant are: (1) use of low bleed controllers, and (2) use of instrume nt air systems. Both are discussed in the Pneumatics Paper. As discussed in Section 3 of this document, PRCI is completing a report that provides details on compressor sta tion mitigation technologies and work practices, associated performance and cost ranges, and factors that influence technical feasibility. That document should be available this summer, and may provi de insight into mitiga tion and cost-related questions from the Pneumatics Paper. We will look forward to participating in review of other technologies and cost information that become av ailable through the PRCI and other reports that may be informative on this emissions source.

At this time, INGAA recommends that differenc es in the National Inventory and Subpart W emission estimates and their underlying methodologies be reconciled so that the contribution of pneumatic controllers to the T&S sector emissi on inventory is appropr iately considered in mitigation strategies going forward. Additional information on the prevalence of low versus high bleed devices and instrument air systems also could be examined to understand how the current inventory may be lower than previous estimates. Additional mitigation may not be required if the total inventory is relatively small and the use of lower emitting units is prevalent. A more refined inventory of pneumatic devi ces across the T&S sector and the corresponding emission estimates should be performed before a thorough analysis of appropriate mitigation technologies and associat ed costs are undertaken.

INGAA does not have recommendations at this time re garding instrument air systems or electricpowered controllers, although these technologies will likely be included in the PRCI report. As noted above, anecdotal information indicates instrument air system s are more prevalent now than when pneumatic controller emission estimates were completed for the EPA-GRI study in the 1990s, but specific information is not available a nd a survey would be required to provide more

detail.

14 This section includes responses relevant to Pneumatics Paper questions 3 -through 7 (mitigation techniques, costs), and question 9 (new studies). Note that question 8 pertains to pumps, which are not prevalent in T&S operations, and therefore is not discussed.INGAA Comments on EPA Pneumatic Devices White Paper June 16, 2014

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Page 9 of 12 EPA also asks about applicati ons where natural gas-driven co ntrollers may be required. T&S compressor stations use natural gas- driven controllers for the large valves that are used to isolate portions of the facility or pieces of equipment. Process control and safety concerns may require use of intermittent natural gas-driven pneumatic controllers to provide a fast response with enough motive force to actuate a rapid valve response.

Gas-driven pneumatic controller s at T&S facilities are require d for safety reasons. Specific pneumatic device examples include, but are no t limited to, mainline block valves, emergency shutdown valves, pipeline or station manifold is olation valves, pressure relief valves, meters, regulators, etc. Natural gas-driven pneumatic c ontrollers are needed to operate these systems to ensure consistent and safe opera tion or closure in emergency situ ations. Natural gas is needed for these applications due to system reliability and safety reasons. Alternative operators driven by instrument air, electricity, solar power or ot her means would not provide the same level of safety or reliability. If electri cal power service at a compressor st ation or gas plant is lost, even for short, temporary time periods, the systems c ontrolled by these pneumatic devices would not be able to operate or close, which could allow pressure build ups potenti ally causing catastrophic equipment failure, pipeline r uptures or explosions.

Finally, one member company analyzed its Subpa rt W emissions data reported to EPA under the GHGRP. The total GHG emissions from pneumatic devices for that company was approximately 1 percent of its total GHG emissi ons for all Subpart W emission categories. EPA

should not focus on methane emission reductions fr om pneumatic devices from the T&S sector given the need for gas-driven pneumatic devices for safety and reliability and the extremely low

GHG emissions from these devices. Other re duction opportunities pr ovide greater methane

emission reductions with lower effort and co st. INGAA would be gl ad to discuss other opportunities.

6. Coordinate Methane Initiati ves Across Agencies and Establish a Primary Point of

Contact As part of the Obama administration’s Climat e Action Plan, the Administration has initiated several efforts that address methane reductions, including revisions to th e EPA Natural Gas STAR Program, launch of the Quadrennial Energy Review , revision of EPA’s GHG RP, the five methane white papers and plans to revi se regulations to control VOC emissions, and possibly methane emissions, from the oil and gas sector. 15 This level of simultaneous activity on a common issue challenges the industry and othe r stakeholders, and coordinati on between industry and between policymakers is crucial. Therefore, INGAA recommends that the Administration establish a primary point of contact responsible for ensuring coordination across the multiple federal agencies and departments tasked with methane-related initi atives impacting the T&S sector. Ideally, this point of contact would provide guidance and assi stance in the development, interpretation and implementation of methane policies. It can be di fficult for the pipeline industry to manage the numerous and sometimes duplicative requests for information from multiple agencies and departments.

15 For example, potential revisions to 40 C.F.R., Part 60, Subpart OOOO.INGAA Comments on EPA Pneumatic Devices White Paper June 16, 2014

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Page 10 of 12 As questions arise about the overall climate change strategy, it would be extremely helpful to have this same primary point of contact within th e Administration to discuss methane and other GHG reduction issues, opportunities, and policies.

7. Conclusion

INGAA and its members are committed to redu cing methane emissions in a prudent and environmentally responsible manner. INGAA an d its members are undertaking initiatives to

understand the sources of T&S sector methane em issions and to identify the most significant

sources and the most cost-effective methane emission reduction strate gies. In summary:

1. EPA should reevaluate whether pneumatics are re levant to the intersta te natural gas (T&S sector. INGAA submits that pneumatics is an upstream issue and not a significant

emission source for the T&S sector.

2. Gas-driven pneumatics are needed for some pr ocess applications to address rapid process control, possibly due to safety concerns, such as large valves that are used to isolate portions of the facility or pieces of equipment.

INGAA appreciates the opportunity to comment on the Pneumatics Paper and will continue to provide EPA with additional inform ation as it becomes available.

Sincerely,

Lisa S. Beal

Vice President, Environment and Construction Policy

Interstate Natural Gas Association of AmericaINGAA Comments on EPA Pneumatic Devices White Paper June 16, 2014

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Page 11 of 12 Appendix A Pneumatics Questions and INGAA Response

1. Did this paper appropriately characterize the di fferent studies and data sources that quantify emissions from pneumatic controllers and pne umatic pumps in the oil and gas sector?

Responses are found in sections three a nd four of the INGAA comment document.

2. Please discuss explanations for the wide range of emission rate s that have been observed in direct measurement studies of pneumatic c ontroller emissions (e .g., Allen et al., 2013 and Prasino 2013). Are these differences driven purely by the design of the m onitored controllers or are there operational characteristics, such as supply pressure, that play a crucial role in determining emissions?

Responses are found in section four of the INGAA comment document.

3. Did this paper capture the full range of tec hnologies available to reduce emissions from pneumatic controllers and pneumatic pumps oil and gas facilities?

Responses are found in sections four and five of the INGAA comment document.

4. Please comment on the pros and cons of the di fferent emission reduction technologies. Please discuss efficacy, cost and feasibility for both new and existing pneumatics.

Responses are found in section five of the INGAA comment document.

5. Please comment on the prevalence of the diffe rent emission contro l technologies and the different types of pneumatics in the field. What pa rticular activities requ ire high bleed pneumatic controllers and how prevalen t are they in the field?

Responses are found in sections four and five of the INGAA comment document.

6. What are the barriers to installing instrument air systems for conver ting natural gas-driven pneumatic pumps and pneumatic controllers to air-driven pumps and controllers?

Responses are found in sections five of the INGAA comment document.

7. Are there situations where it may be infeasible to use air driven pumps and controllers in place of natural gas-driven pumps and c ontrollers even where it is feasible to install an instrument air system?

Responses are found in sections five of the INGAA comment document.

8. Did this paper correctly characterize the limita tions of electric-powered pneumatic controllers and pneumatic pumps? Are these electric devices appl icable to a broader ra nge of the oil and gas sector than this paper suggests?

No INGAA Response – Not prev alent in the T&S sector.INGAA Comments on EPA Pneumatic Devices White Paper June 16, 2014

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Page 12 of 12 9. Are there ongoing or planned studies that will substantially improve the current understanding of VOC and methane emissions from pneumatic controllers and pneumatic pumps and available techniques for increased product reco very and emissions reductions?

Responses are found in sections four and five of the INGAA comment document.